United States Environmental Protection Agency, Region 9

Air Division

Technical Support Document

for

EPA’s Notice of Proposed Rulemaking

for the

California State Implementation Plan

Antelope Valley Air Quality Management District’s

Rule 1134, Stationary Gas Turbines

Prepared by: Idalia Perez

Decem ber 20 11Page 2 of 4

Antelope Valley Air Quality Management District ( AV A QM D)

Submitted Rule AVAQMD Rule 1134

, Stationary Gas Turbines

 Amended: January 19 , 2010

 Submitted: July 20 , 20 10

 Determined complete : August 25, 2010

Previous Rule Submittals There are no outstanding submittals of Rule 1 134

.

SIP

- Approved Rule

 Adopted: December 7

, 1995

 EPA approval: November 1, 1996 (61 FR 56470)

Rule Summary

Rule 1 1 34 regulates emissions of oxides of nitrog en ( NOx ) and carbon monoxide (C O ) from stationary gas turbine systems with ratings equal to or greater than 0.3 MW

.

The emission limits in the Rule are in Table 1 (Section C) and are shown below : Control Operating

hours per year Rating

(MW) NOx limit (pp m @ 15% O 2 ) CO limit (ppm

@ 15% O 2 ) Gas fuel Liquid fuel

SCR + DLN > 877 > 10 5 25 200

DLN > 877 2

– 10 25 65 200 SCR (no DLN available) > 877 2

– 10 35 65 200

DLN > 877 < 2 42 50 250

SCR or DLN < 877 > 10 25 42 200 Any (fired on digester and/or landfill gas) any 0.3

– 10 25 N/A 200

The rule language includes definitions (Section B) and exemptions (Section D) . M onitoring

, recordkeeping and reporting requirements are contained in various provisions in Section s E, F

, G

, H and I.

Impact on Emissi ons According to doc umentation sent along with the r ule submittal, the District does not expect a

reduction in emissions due to the implementation of this rule because there are no existing sources affected by the r ule

. The only turbine currently located i n the District is a microturbine that is below the size threshold for Rule 1134 and is hence not subject to the rule.

Rule Evaluation Criteria We have primarily used the following three criteria to evaluate Rule 1 134 :Page 3 of 4

Rule Stringency Section 172(c)(1) o f the Clean Air Act ( CAA) requires nonattainment areas to implement all reasonably available control measures (RACM), including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, of reasona bly available control technology (RACT), as expeditiously as practicable. O zone nonattainment areas classified as moderate or above must require RACT for all major sources of NOx. CAA § 182(b)(2) & (f) ; 40 CFR § 51.912(a)

. The AVAQMD regulates an ozone non attainment area classified as moderate

for the 8

- hour NAAQS and severe

- 17 for the 1

- hour NAAQS (see 40 CFR part 81) , thus

Rule 1 143 must fulfill RACT requirements for NOx

.

Enforceability CAA s ection 110(a)(2)(A) requires that regulations submitted to EPA for approval into a State Implementation Plan (SIP) must be clear and legally enforceable.

SIP Revisions CAA s ection 110(l) prohibits EPA from approving any SIP revision that would interfere with any applicable requirement concerning attainment and reas onable further progress (RFP) or any other applicable requirement of the CAA. In addition, CAA

s ection 193 prohibits the modification of any SIP

- approved control requirement in effect before November 15, 1990, in a nonattainment area.

Guidance and policy documents that we used to define specific enforceability and RACT requirements include the following:

 Issues Relating to VOC Regulation, Cutpoints, Deficiencies, and Deviations (the “ Blue

Book ” ), US EPA, OAQPS (May 25, 1988).

 Guidance Document for Correct ing Common VOC and Other Rule Deficiencies , EPA Region IX (August 21, 2001, the “ Little Bluebook ” ).

 State Implementation Plans; General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990, 57 FR 13498 (April 16, 1992); 57 FR 18070 (April 28, 1992).

 State Implementation Plans; Nitrogen Oxides Supplement to the General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 (the “ NO X Supplement to the General Preamble ” ), US EPA, 57 FR 55620 (November 2 5, 1992).

 Alternative Control Technology Document, NOx Emissions from Stationary Gas

Turbines , US EPA, 453/R

- 93

- 007 (January 1993) http://www.epa.gov/ttncatc1/dir1/gasturb.pdf

 Determination of Re asonably Available Control Technology and Best Available Retrofit Control Technology for the Control of Oxides of Nitrogen from Stationary Gas Turbines

, California Air Resources Board (May 18, 1992) http://www.arb.ca.gov/research/apr/reports/l3092.pdf

 Status Report on NOx Controls for Gas Turbines, Cement Kilns, Boilers, and Internal Combustion Engines ; Northeast States for Coordinated Air Use Management ( NESCAUM, December 2000) http://www.nescaum.org/documents/nox

- 2000.pdf

Evaluation of Rule Stringency

We believe Rule 1 134 implements RACT for Antelope Valley for reasons including:Page 4 of 4

- The 1993 ACT provides technical information inc luding control techniques and achievable controlled NOx emission levels from stationary gas turbines. Rule 1 134 requirements are in alignment with levels of controls that the ACT shows are

achievable

.

- Rule 1134 requirements are more stringent than tho se d etermined t o be RACT in the

1993 ARB RACT/BARCT determination.

- The limits i n the rule are consistent with what the 2000 report by NESCAUM

determined to be feasible for retrofit installations.

- The limits in the rule are comparable to limits in other Air Di stricts in California (e.g. San Joaquin Valley Unified APCD Rule 4703).

Since no CTG has been issued recently for this activity, we do not have clear national guidance defining presumptive RACT. However, we believe the analysis summarized above suffic ien tly

demonstrates that Rule 1 1 34 implements RACT.

Evaluation of Enforceability and SIP Revision Criteria Recordkeeping and other compliance provisions in the rule ensure that the requirements are adequately enforceable.

The submitted rule has a wider applicability and more stringent emission limits than the currently SIP approved rule

, thus strengthening the requirements of the SIP. Therefore, w e propose to determine that a approval of the sub mittal would comply with CAA s ection s 110(l) and 193

because (1) the proposed SIP revision would not interfere with the on

- going process for ensuring that requirements for RFP and attainment of the NAAQS are met, and (2) the submitted SIP revision is more stringent than the existing SIP requirements

.

Suggested Ru le Improvements Although not currently basis for rule disapproval, EPA recommends that the AVAQMD make the following improvements in the next revision of Rule 1 134

.

1. The exemption for Chemical Processing Gas Turbine (Section (D)(1)(c)) should be

eliminated or further explained. This is not currently a basis for rule disapproval as there are no major sources in the AVAQMD that are subject to this exemption.

2. To facilitate compliance determinations, we recommend amending the rule to require that

all testing and other records be maintained for 5 years.

Recommendation

Based on the discussion above, Rule 1 134 fulfills relevant Clean Air Act requirements for SIP approval and EPA staff recommend s approval of AVAQMD s ubmitted Rule 1 1 34 for incorporation into the C alifornia Applicable SIP.

Other References

1. SIP approved Rule, amended December 7

, 1995

2. Submitted Rule 1 134

3. Staff Report

, dated January 19, 2010